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Dear RDG Friends, I know that has been some hand wringing about whether American styled ( remedial?) constructive trusts exist in English law. I would be much obliged for references to any writing on 1. arguing for the importation of the US remedy to English law, 2. criticizing the US approach as ill suited for English law, or 3, any comparative analysis of the two modes (and whether the thinking expressed in Chase Manhattan Bank is still the current view) If I correctly recall, both Lords Millett and Browne-Wilkinson have written against the US practice. Any pointers in the right direction would be most welcomed.
Many thanks in advance, Chaim Saiman
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